https://www.taxtmi.com/circulars?id=53481 The draft rules propose computing Arm's Length Price using a range concept limited to TNMM, RPM and CPM: select at least nine comparables matched on FAR, use three years' data with weighted averages of the chosen profit level indicator by aggregating numerator and denominator, and treat the 40th-60th percentile as the range. If the tested party's transfer price lies outside that range, the median of the range is taken as ALP; if within the range, no adjustment is made. Multiple-year data is mandatory for these methods, with limited two-year exceptions and use of current-year data permitted at audit. en-us Thu, 21 May 2015 00:00:00 +0530 Fri, 22 May 2015 13:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/circulars?id=53481 The draft rules propose computing Arm's Length Price using a range concept limited to TNMM, RPM and CPM: select at least nine comparables matched on FAR, use three years' data with weighted averages of the chosen profit level indicator by aggregating numerator and denominator, and treat the 40th-60th percentile as the range. If the tested party's transfer price lies outside that range, the median of the range is taken as ALP; if within the range, no adjustment is made. Multiple-year data is mandatory for these methods, with limited two-year exceptions and use of current-year data permitted at audit. Circulars Income Tax Thu, 21 May 2015 00:00:00 +0530 https://www.taxtmi.com/circulars?id=53481